Organizations holding federal contracts are required to comply with regulations set and enforced by the Office of Federal Contract Compliance Programs (OFCCP). A lot of the guidance on what those regulations require is out of date: Executive Order 11246 was rescinded, new contract thresholds took effect last fall, and enforcement resumed after months of suspension.
Whether you're a new federal contractor sorting out your obligations for the first time, or an existing one making sure nothing has changed on your watch, this post covers what the OFCCP requires right now.
The Office of Federal Contract Compliance Programs (OFCCP) is a division of the U.S. Department of Labor. It enforces affirmative action and equal employment opportunity requirements specifically for organizations that do business with the federal government.
The OFCCP is separate from the Equal Employment Opportunity Commission (EEOC), which enforces general employment discrimination law for all employers. OFCCP jurisdiction applies specifically to federal contractors and subcontractors, and it comes with affirmative action obligations that go beyond what general employment law requires.
The OFCCP enforces compliance through scheduled evaluations of a contractor's practices and documentation, and through complaint investigations. Contractors found out of compliance can face contract cancellation, debarment from future federal contracts, and referral to the Department of Justice.
For most of its history, OFCCP also enforced affirmative action requirements based on race, sex, and national origin under Executive Order 11246. That requirement was rescinded in early 2025. The two laws that remain fully in force are VEVRAA (protected veterans) and Section 503 of the Rehabilitation Act (individuals with disabilities).
A: Federal contractor compliance is a broad term covering all regulatory obligations that apply to organizations doing business with the federal government. That includes procurement rules under the Federal Acquisition Regulation (FAR), prevailing wage requirements under the Davis-Bacon Act, workplace safety standards, and labor and employment obligations enforced by the OFCCP.
Federal contractor compliance under current regulations centers on two statutes.
VEVRAA prohibits federal contractors from discriminating against protected veterans and requires affirmative action to recruit, hire, promote, and retain them. Protected veterans include disabled veterans, recently separated veterans (within three years of discharge), active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. The OFCCP publishes an annual hiring benchmark for what percentage of new hires should be protected veterans based on their share of the civilian labor force. The current annual hiring benchmark, effective July 30, 2025, is 5.1%
Section 503 prohibits discrimination against qualified individuals with disabilities and requires contractors to take affirmative action in their recruitment and employment practices. The utilization goal under Section 503 is 7%: contractors should aim to have at least 7% of their workforce in each job group be people with disabilities. Like the VEVRAA benchmark, this is a goal that measures good-faith effort, not a quota with automatic penalties for missing it.
OFCCP compliance obligations are triggered by contract dollar thresholds. As of October 1, 2025, those thresholds were updated:
VEVRAA (veterans):
$200,000 or more in federal contracts: basic nondiscrimination and affirmative action obligations apply
$200,000 or more AND 50 or more employees: a written Affirmative Action Program (AAP) is also required
Section 503 (disability):
$20,000 or more in federal contracts: basic nondiscrimination and affirmative action obligations apply
$20,000 or more AND 50 or more employees: a written AAP is also required
The previous thresholds were $150,000 for VEVRAA and $15,000 for Section 503. If your organization was borderline under the old figures, it's worth confirming whether you still meet the updated thresholds. Both direct federal contractors and subcontractors at every tier can be covered.
For contractors that meet the applicable thresholds, OFCCP compliance centers on four practical obligations.
Written Affirmative Action Programs (AAPs)
Contractors who meet both the dollar threshold and the 50-employee threshold must maintain written AAPs for veterans (under VEVRAA) and for people with disabilities (under Section 503). Each AAP must include an annual hiring benchmark or utilization goal, data tracking on applicants and hires by protected status, and documentation of outreach efforts. AAPs must be updated annually and made available during a compliance evaluation.
Job posting obligations
Under VEVRAA, contractors must list virtually all job openings with the appropriate State Employment Service Delivery System (ESDS), commonly called the state job bank. The main exemptions are executive and senior management positions, positions filled from within, and positions lasting three days or less.
Outreach and documentation
Contractors must conduct documented outreach to veterans and people with disabilities. That means building and maintaining relationships with local veterans' employment representatives, veterans' service organizations, state vocational rehabilitation agencies, and similar community resources. All outreach must be documented.
Self-identification and recordkeeping
Contractors must invite applicants to voluntarily self-identify as a protected veteran or person with a disability at two points: before an offer is made (pre-offer) and after an offer is accepted (post-offer). Records of job postings, applicant data, and outreach activity must be retained for a minimum of two years, or three years for contractors with 150 or more employees or $150 million or more in contracts.
The OFCCP suspended compliance evaluations in early 2025 as part of broader regulatory uncertainty. That abeyance was lifted in July 2025, and scheduled compliance evaluations resumed. For FY2026, Congress funded OFCCP at approximately $101 million, maintaining the agency's oversight capacity under VEVRAA and Section 503. The agency is active and conducting reviews.
Contractors who let documentation lapse during the abeyance period should take stock now. Gaps in documentation are significantly easier to close before a compliance review than during one.
A: Executive Order 14398, signed March 26, 2026, requires federal contractors to certify they do not engage in racially discriminatory DEI activities. It is enforced through contract clauses, not OFCCP compliance evaluations. It does not replace or modify VEVRAA or Section 503 obligations, which remain separate and fully in force. EO 14398 is currently subject to legal challenge; consult legal counsel for guidance specific to your organization.
For more on how the regulatory environment shifted in 2025, see the OFCCP Compliance 2026 guide.
Three issues show up more often than any others:
State job bank posting gaps. This is the single most common finding. Jobs that weren't posted to the ESDS, postings that went out late, or exemptions claimed incorrectly. If you're managing this manually, it's easy to miss.
Incomplete outreach documentation. The requirement isn't just to conduct outreach. It's to document it. Phone calls that weren't logged, relationship activities that weren't recorded, and annual evaluations that are vague or missing will all create problems in a review.
Inconsistent self-identification collection. Pre-offer and post-offer self-ID needs to happen consistently across every hire. Gaps in collection or variations in process across different hiring managers are a common issue.
All three come down to process reliability at scale. JobTarget's Compliance Suite automates state job bank posting, outreach documentation, and proof storage directly inside your existing hiring workflow, so compliance doesn't depend on anyone remembering to do it manually.
If you're evaluating tools, see how federal contractor compliance software options compare.
Compliance obligations are triggered by federal contract dollar thresholds. Basic VEVRAA obligations apply at $200,000 or more in contracts (effective October 1, 2025); Section 503 obligations apply at $20,000 or more. Contractors with 50 or more employees and contracts above those thresholds must also maintain a written Affirmative Action Program
An Affirmative Action Program (AAP) is a written plan that documents a contractor's commitments and activities related to veteran and disability hiring. It must include a hiring benchmark or utilization goal, data tracking on applicants and hires by protected status, and documentation of outreach efforts. AAPs must be updated annually and made available for review during a compliance evaluation.
Yes, but a narrower one. The rescission of EO 11246 in early 2025 eliminated the requirement to maintain AAPs based on race, sex, and national origin. AAPs for protected veterans (under VEVRAA) and people with disabilities (under Section 503) remain required for contractors who meet the applicable thresholds.
Contractors who fail to demonstrate compliance may face contract suspension or cancellation, debarment from future federal contracts, and referral to the Department of Justice. OFCCP typically works with contractors to develop conciliation agreements before escalating to debarment. The most effective protection is documentation that demonstrates a sustained, good-faith compliance effort.